(LVEDA)
And
Land Use
Advisory Committee
(LUAC to
the
Permit
Processing Issues
(with follow-up comments from Chuck’s & Richard’s meeting
with county personnel Robert Eland First District Field Rep, Julie
Rynerson-Rock Director of LUSD, Jim Squire Advanced Planning, Terrie S.
Williams Public Health Program Manager, Michael Farrell Supervising
Environmental Health Specialist and Douglas Crawford Planning & Engineering
Supervisor County Fire Protection District on August 19, 2009 at the First
District’s Supervisor’s office in Hesperia)
The following is a discussion of issues that
LVEDA and LUAC have observed as problems with the processing of planning and/or
building permits in the
DEVELOPMENT CODE ISSUES:
A.
Infrastructure
Requirements:
The current
Development Code (April 2007) has been stripped of the Improvement Levels from
the previous General Plan, which offered some rural infrastructure requirements
(IL-4 & IL-5), which gave rural communities a break from the more rigid
urban type requirements. The current code’s infrastructure requirements are the
same now for any commercial zone development without regard to community type
and location.
Discussion:
On-site paving
requirements are a problem for rural areas due to the concentration of run-off
that has to be addressed by the Strom Water Pollution Prevention Plan. This run-off could be minimized by some
pervious surfacing for on-site parking like gravel. The old IL-4 & 5
requirements helped mitigate some of this. This could be a standard for smaller
projects under 10,000 square-foot buildings as an example. The off-site
improvements can be very expensive for a small commercial project especially
when on a state highway.
Follow-up:
STANDARDS THAT WERE IN THE GENERAL PLAN ARE NOW IN
CODE. NOW MORE VISIBLE AND
APPLICABLE - AND MORE SUBJECT TO INTERPRETATION. (CB)
IN GENERAL, WE GOT THE IMPRESSION THAT THESE REPS ARE
IN FAVOR OF RELAXING STANDARDS TO BRING BACK SOME RURAL STANDARDS AND JULIE AND
JIM EVEN SUGGESTED THAT THE DEVELOPMENT CODE TO INCORPORATE THIS (SIMILAR TO
THE TABLES OR VIA A NEW CHAPTER). WE DIDN’T GET THE IMPRESSION THAT THIS WILL
BE DONE SOON. (RS)
B.
Rural
Standards:
The current
development code doesn’t differentiate rural from urban other than the zoning
district of Rural Commercial (CR), which was created under the old code, which
at the time did have the rural improvement levels to consider.
Discussion:
Since the CR LUD does
allow for a broader range of commercial uses than the other more urban
commercial districts allow, we believe that this is attributed to the rural
nature of these communities like
FOLLOW-UP:
PLANNING CONSIDERING “LOW IMPACT STDS.” – MAYBE BRING BACK “IMPROVEMENT LEVEL” CONCEPT. DO WE WANT A “TIGHT CODE” VS.
LOOSER TO ALLOW INTERPRETATIONS? (CB)
DIDN’T FEEL THAT THE
C.
Code
Amendments:
Since this
discussion may eventually lead to the topic of how and whom shall initiate
rural standards, it’s a good idea to rely on the county for direction here.
Discussion:
How could these rural
standards be implemented? Usually it’s a Development Code Amendment type of
application for the public to initiate when the public wants to make a revision
or add something to the code. It would
seem that the county can initiate these standards in the same manner as
advanced planning is handling the current development code updates at this
time. We believe that the new development code left out these standards. After
all, rural standards were a consideration back when the code was going through
its restructuring.
FOLLOW-UP:
THE 4TH SET OF CODE AMENDMENTS IS NOW
GOING BEFORE THE BD. OF SUPS. MORE TO FOLLOW. (CB)
D.
Use
Permits:
The development
code sets out which applications shall be used for what types of project
proposals. Most common for commercial development is the Minor Use Permit or
the Conditional Use Permit.
Discussion:
It would seem that if
some rural standards could be established, which would be based around a
smaller business model, and then the planning use permit process could be made
simpler, and less costly. Part of the rural development problem is the enormous
cost to develop a small project when the development standards are the same for
the little guy as they are for the big-box builder. We think that a Site Plan
Permit type of application could be used for this. We understand that it would
mean that the county will have to get CALTRANS to get on board in regards to their
highway standards but that doesn’t seem to be such a hard issue when they
already have basic two-lane highway standards established.
FOLLOW-UP:
NOT SPECIFICALLY DISCUSSED – BUT SHOULD CONSIDER?
(CB)
WE TOUCHED ON THIS IN A ROUND ABOUT WAY THROUGH SOME MORE
GENERALIZED DISCUSSION BUT STAFF DIDN’T OFFER ANY SOLUTIONS HERE. (RS)
E.
County
Departments Consolidation:
The need to
have all county agencies that impact a project to be readily available is
extremely important.
Discussion:
We hear it all the time;
applicants complain about all the different agencies that they have to satisfy,
or jump through hoops with, to get a “sign-off” so they can get their building
permit. We understand that Supervisor Mitzelfelt has been pushing for a new
government center that will be built in Hesperia. This is a good step the right
direction but it will not help if it means that it’s business as usual but in
new digs. We need more agencies to be represented in the high desert. It might
also be good to take a look at how the planning process operates with the
current de-centralized manner that the process now takes.
FOLLOW-UP:
NEW
THAT SUMS IT UP! (RS)
F.
Code
Interpretation:
The
development code leaves much too discretionary interpretation. It appears that
the code leaves too many loopholes, which are hard to identify until the time
comes when an applicant has an issue that tests it. Look at the current
“Agri-tourism” definition and requirements for example. There is a current
application for a Guest ranch in
Discussion:
It appears that the code
needs to close the loopholes and better define uses and how they can be
developed. Just when you think it’s all covered, somebody comes along to
challenge the text. Do you know that we can’t find parking requirements for
museums. We needed an interpretation for this one. Maybe the code needs to
cover more types of uses instead of lumping similar uses in with those that are
defined. It’s also a problem when the code is inconsistently interpreted
between different department personnel.
FOLLOW-UP:
HERE IS WHERE JULIE COMMENTED ON THAT THE
CODE SHOULDN’T BE TOO TIGHTLY WRITTEN, ALLTHOUGH I DON’T QUIT AGREE WITH THAT!
DID CONCEDE THAT THIS IS A PROBLEM AND HAS BEEN THROUGH THE YEARS WITH
PERSONNEL CHANGES, ETC. JULIE IS PUSHING FOR MORE “COMMON SENSE” TO BE USED
WHEN INTERPRETATIONS ARE NEEDED. (RS)
APPLICATION PROCESS ISSUES:
A.
Pre-application
Conferences:
The county has
a process for pre-application. There are two applications, “Pre-Application
Conference” and “Pre-Application Development Review”. The former is a $1225 fee
and the later is a $4000 fee.
Discussion:
These two applications
virtually use the same submittal lists, which is confusing. The former
application should be one of lesser submittal requirements so as to review potential
projects, to help an applicant better decide the validity of the proposal. We believe that this is the purpose of the
former application. The later application, we believe, would be for a more
complicated project. If this is correct, then more information and planning
needs to be done for the process. Also, the DRC used to be a process that
accomplished the same thing but today it’s only used to review Parcel Maps
during the process. We think that the DRC process should be expanded to include
all types of projects to give the applicant the opportunity to meet with all
department representatives to get all the marbles on the table long before the
process gets too deep. This could help save applicants a lot of investment if
the development conditions are getting to be too overwhelming.
FOLLOW-UP:
PLANNING TO
REVIEW PRE-AP OPTIONS. CURRENT SYSTEM
PROVIDES THIS
JULIE
SEEMED OPEN TO USING DRC AS AN OPEN FORUM. THEY SEEMED
INTERESTED IN THE TOWN OF
B.
Accountability:
This
discussion focuses on not only cost accounting transparency but personal
accountability of the interaction by staff with the applicant.
Discussion:
It has been brought to
our attention that some applicants feel that the cost of the process hasn’t all
together been fair. When one
FOLLOW-UP:
BUDGETS OF
EHS/BUILDING-SAFETY/CURRENT PLANNING (NOT ADVANCED PLANNING) ARE ENTIRELY FEE
BASED – CREATING PROBLEM OF STAFF NEEDING TO CHARGE ITS TIME TO SPECIFIC
PROJECTS – OR INFLATE PERMIT FEES TO COVER SAID COSTS – DILUTING ABILITY TO
WORK WITH THE PUBLIC PRIOR TO APPLICATIONS.
WE ALL AGREED THAT CURRENT PLANNING SHOULD HAVE ACCESS TO THE GENERAL
FUND TO FULFILL ITS “PUBLIC” RESPONSIBILITIES.
SPECIFIC EXAMPLE CITED OF AN APPLICANT’S PROJECT BEING BILLED FOR “STAFF
TRAINING”.
PLANNERS “DO” VISIT SITE PRIOR TO PROCESSING
APPLICATIONS. EHS GOES TO SITE WHEN
NECESSARY. NOT SURE ABOUT FIRE??? (CB)
AS FAR AS THE PHONE “OK’S”, JULIE AGAIN BRINGS UP THE
“COMMON SENSE” ISSUE. NO REAL COMMENT HERE. (RS)
C.
Process
Time Frame:
When planning
applications are filed the first question from the applicant is “how long will
this take”. Time studies seem to be
lacking as a tool for this question.
Discussion:
More often than not, the
process ends up taking twice, or more, longer that expressed at the counter the
day the applicant filed the project. We understand that when projects are on
state highways that CALTRANS is involved and this is one area that really needs
to be improved. CALTRANS can take up to 6 months to review a planning
application and feed back to the case planner the required conditions. Of all
agencies you would think that this one would be one of the most efficient.
Since they are only concerned with roads, it should be a quick and simple
matter to establish their requirements and feed this back to the planner. We
would suggest that the county try to work with CALTARNS to help close this gap.
With this being said, the county process still seems to be bogged-down within its
own departments. The planner waiting for comments from the others to eventually
establishing the ultimate “Conditions of Approval” We believe that the county
could do a better job in this area. We don’t have the answers but I’m sure
someone in the process line might have some good suggestions.
FOLLOW-UP:
ACKNOWLEDGED
AS MAJOR PROBLEM – BUT APPLICANT’S NEED TO PROVIDE FULL PROJECT DETAIL UP-FRONT. SUBSEQUENT CHANGES ONLY PROLONG THE PROCESS –
BUT SOME ARE REQUIRED DUE TO DEPT. STIPULATIONS REVEALED LATER IN PROCESS (IE:
CALTRANS AND FIRE).
COUNTY HAS SAME PROBLEMS WE DO. ROBERT SENDING OUR LIST TO LAURIE HUNTER (FIRST DIST. REP. HANDLING
CALTRANS ISSUES). CONSIDER A MOU
WITH CALTRANS RE: HWYS 18/247 STANDARDS/IMPROVEMENTS REQUIRED FOR COMMERCIAL
DEVELOPMENT?
CALTRANS NEEDS A PUBLIC ADVISOR FORUM TO EXPEDITE RESPONSES TO
APPLICATIONS FILED WITH COUNTY. (CB)
IT MAYBE A GOOD IDEA TO TRY TO MEET WITH THEM SEPARATELY.
(RS)
CONDITIONS OF APPROVAL AND THE RESULTING EFFECTS:
A. All projects go through
the same basic process to ultimately establish the conditions from all
departments for obtaining building and/or grading permits or map recording. These
conditions have a “make or break” effect on the outcome of the project, the
viability of the project.
Discussion:
A Minor Subdivision can
end up costing so much in meeting conditions that the entitlement ends up being
more than the value of the rural land to begin with. Certain requirements
should be deferred to the time when an owner is ready to pull building permits,
like percolation tests, roads improvement, etc. This affects parcel maps more
than actual developments. Possibly some improvements for rural development of
commercial and industrial uses could be bonded for future development. And,
again, some rural standards should be established, (like the old IL), to help
relieve development costs in these generally poorer communities. Gravel parking
areas for better on-site percolation helps with the storm water run-off instead
of the current required paved parking requirements. Also, small projects should
be relieved of most off-site improvement conditions due to the large percentage
of project cost that results from this. Certainly a weekend farmers market shouldn’t
have to make major improvements to the state highway. This all boils down to a
need for rural development standards.
FOLLOW-UP:
THIS DISCUSSION GOT PASSED-UP SINCE NO ONE
FROM PUBLIC WORKS OR LAND DEVELOPMENT-ENGINEERING WAS PRESENT. (RS)
BUILDING DEPARTMENT AND CODE ENFORCEMENT ISSUES:
A.
Code
Enforcement:
The community
expects that Code Enforcement will investigate complaints and follow-up through
to a resolution.
Discussion:
It appears that in the
past Code Enforcement hasn’t been able to follow-up on all complaints to a point
to see if a violation has occurred and then to resolution. Also, there has been
some fuzzy interpretation of the site clearing issue, is it “grading” or not.
Does the Building Department have jurisdiction or not. Was the Development Code
clear on this or not. Recently there have been some land clearing done in
Lucerne Valley on a large scale (many acres) that have the effect of creating
fugitive dust. These instances have been complained about to Code Enforcement,
but it was a year ago. So now, in one case, there is a planning application on
file for an 80-acre project in the north valley. We have requested some
mitigation be done but we are not clear if the development Code properly
addresses this instance and it may leave it up to interpretation for the final
answer. We would expect that this be more clearly defined by the Development
Code. We would expect the Building Department to take a stronger position on
this issue with possible fine. Pre-clearing land before filing an application
will eliminate the need for the biological survey and the need to address the
endangered species issues. It now seems more profitable to do the deed and then
deal with the consequences later. It may be better to give Code Enforcement
more power over these conditions since some of these infractions may not
involve a building or grading permit. It’s also a problem when the community
doesn’t know what the rules are about land clearing. Most don’t know that you
can only clear up to an acre and it’s very common to see a lot more acres
cleared, then, we have the dust issue.
FOLLOW-UP:
COUNTY AGREES
THESE ARE PROBLEMS. FOR IMMEDIATE
RESTITUTION- WE SUGGEST REQUIRING WETTING DOWN ILLEGALLY GRADED/DE-BRUSHED
PARCELS WITH A WATER TRUCK IF IRRIGATION IS NOT AVAILABLE – PLUS A FINE TO
COVER STAFF ENFORCEMENT TIME. COUNTY’S
PENDING “ADMIN. PROCESS” (IN LIEU OF TIME-CONSUMING COURT ACTION) MAY EXPEDITE
SUCH ENFORCEMENT. (WE WILL SEE IF IT WORKS). (CB)
CODE ENFORCEMENT
NOR BUILDING DEPARTMENT WERE PRESENT SO THIS IS AS FAR AS THE DISCUSSION WENT!
(RS)
FIRE DEPARTMENT CONDITIONS:
A.
Commercial
vs. Residential Requirements:
When filing a
use permit of any type, the Fire Department has a review fee to pay on top of
the planning deposit and the health department fee.
Discussion:
When Mr. Squire attended
the June LVEDA meeting and the topic was brought up, he admitted to being
surprised that upwards of a $2100 additional fee would have to be paid to the
Fire Department to review a Minor Use Permit application. He thought that the
planning deposit was supposed to cover this. It may be that the Fire Department
has to cover their own costs this way but it doesn’t seem that the fees charged
by them is proportionally fair to the work they put into reviewing the project.
The resulting conditions always seem to be boiler-plate in nature and not very
specific to the type of project, especially in
FOLLOW-UP:
DOUG CRAWFORD WAS SYMPATHETIC TO THIS
CONCERN BUT THAT WAS ABOUT ALL. THERE WAS NO REAL DISCUSSION ABOUT THE FEE
ISSUE SINCE THAT IS THE WAY IT IS. DOUG DID RECOGNIZE THE CONCERNS. (RS)
ENVIRONMENTAL HEALTH SEVICES:
A. Conditions of Approval:
EHS gets to input into all projects conditions as like other
agencies but in many instances the conditions don’t seem to fit the use.
Discussion:
Again, we see
boiler-plate conditions established that may not apply to the project and take
up a lot of extra time by the applicant to prove that a certain condition
doesn’t apply to his/her project. Also, timing of when something is needed is
important, like when do you really need a percolation test. Some locations
shouldn’t need this at all if previous tests have been made in the past and an
engineer can qualify a parcel with the previous established testing and /or
systems that exist in the area. Again, rural standards could adopt this type of
policy.
FOLLOW-UP:
TERRIE SEEMED INTERESTED IN THIS ISSUE AND
ACKNOWLEDGED THAT SOME PROBLEMS EXIST IN THE DEPARTMENT. NO RESOLUTION OFFERED.
(RS)
B. Hauled Water:
It appears
that EHS doesn’t want people living on hauled water anymore.
Discussion:
We hear that people can’t
get a building permit because their property is in an area where they need
hauled water. Some areas of the desert are not compatible to drill water wells
(bad water or no supply) so they are denied the use of their property because
hauled water is not allowed. A citizen of this country shouldn’t be refused the
right to occupy his land just because water isn’t present or it’s too bad to
utilize. This seems to border a constitutional issue of property rights. There
are plenty of qualified potable water haulers available in most rural
communities to fill the need for water.
FOLLOW-UP:
NOT MANDATED BY
STATE – WHICH ONLY ENFORCES “LEGAL WATER HAULING”. THIS IS STRICTLY A
(OUR
POSITION): IN INSTANCES WHERE GROUNDWATER IS
NOT AVAILABLE – OR ITS QUALITY UNACCEPTABLE FOR DOMESTIC USES – HAULING SHOULD
BE ALLOWED WITH STIPULATION REQUIRING “LEGAL HAULER”. BOTTOM-LINE: THE COUNTY ALLOWS A RESIDENCE – EVEN IN
REMOTE RC ZONING. LANDOWNERS PURCHASED
SAID LAND ACCORDINGLY. A RESIDENCE
REQUIRES WATER. TO WITHHOLD A BUILDING
PERMIT OR PROHIBIT HAULING DENIES SAID OWNER THE “RIGHT” TO BUILD ON LAND WHICH
PERMITS IT. THIS IS NOT ONLY A “CATCH
22” ISSUE – BUT A CONSTITUTIONAL ONE AS WELL.
THE FIRST AND
THIRD DISTRICTS NEED TO GET THIS POLCIY RESCINDED – WITH CLARIFICATION RE: WHEN
AND WHEN NOT ALLOWED! IF AN AFFADAVIT
FROM A LICENSED HYDROLOGIST – OR CURRENT EMPIRICAL KNOWLEDGE - INDICATES THE
ABSENCE OR POOR QUALITY OF UNDERLYING GROUNDWATER – HAULING MUST BE ALLOWED. (CB)
THAT SAYS IT!!
(RS)
CALTRANS:
A. Policies for state
highways:
The rural
communities have always struggled when dealing with this great big state
agency.
Discussion:
It should be apparently
clear as to what conditions a project proponent can expect when it comes to
highway improvement. The folks at CALTRANS may say that they are available to
discuss your project but more times than not, they are not really available.
You are lucky to catch them when you are there. Communities should know what CALTRANS
has in store, planning-wise, for the state highways that traverse their town.
In
FOLLOW-UP:
SEE PAGE 5, ITEM C. PROCESS TIME FRAME:
FOLLOW-UP DISCUSSION. (RS)
PUBLIC ADVOCATE:
A. There appears to be a
need for the public to gain help with the application process since it has
become so drawn-out a more complicated than what the average citizen can
comprehend.
Discussion:
It has recommended that a
Public Advocate be established to help applicants work with the county through
the application process. This may not be needed when an applicant is a planning
and/or design professional, or represented by one, but many times people will
prepare and submit their own applications. The application may make it through
acceptance but usually much information is missing or at least lack clarity.
This may aid in a smoother process when the applicant has someone on his/her
side that understands the process and issues.
FOLLOW-UP:
WHEN THIS ITEM CAME UP, JULIE CAME BACK
WITH “CALL ME” AND PASSED OUT HER CARD. SO, IN FACT, SHE WILL BE THE ADVOCATE.
(RS)
ENVIRONMENTAL ISSUES:
A.
Biological
Issues:
One of the
largest issues to deal with is the endangered wildlife habitat issues,
especially the Mojave Ground Squirrel in the high desert. Some areas have to
deal with the Desert Tortoise as well as other creatures.
Discussion:
We feel that the county
could help the communities by further establishing the Mojave Ground Squirrel
habitat by preparing some trappings to see if they really exist. Recently, we
obtained a new map from the “West Mojave Plan” and we see that
FOLLOW-UP:
AT VERY LEAST
– COUNTY/BIA/ETC. NEED TO FORCE THE ISSUE – IE: A SPRING TRAPPING PROGRAM IN
KEY AREAS OF THE MOST SUITABLE HABITATS WITHIN THE SOUTHEASTERN FRINGES OF
DFG’S RANGE MAPS. IF NOT FOUND – “NOT
HERE”. PER JULIE: COULD BE HANDLED VIA
EIR ON COUNTY’S IMPLEMENTATION OF WEST MOJAVE PLAN. (CB)
I THOUGHT THAT JULIE WAS REALLY TRYING TO
GET A HANDLE ON THIS BY HER SUGESTION. HOPE IT WILL WORK. (RS)
ADDITIONAL TOPICS:
The following
are additional topics that had risen during this discussion with LVEDA and LUAC
but are included as bullet points for further discussion;
·
Have
professional planning consultant (entity) perform an
auditing of the application process.
NOT
DISCUSSED AND NOT LIKELY? BEING DONE INTERNALLY NOW. (CB)
·
Legal
vs. physical access; we see that the Building Department is going to initiate
an informal (not recorded) agreement with building permit applicants regarding
status of legal, or not access, to be on file. This mostly affects residential
permits. This is a step in the right direction but we are concerned that the
“agreement” will be lost in the files when years pass by and the property
affected changes ownership. Should this be a more formal recorded document?
IF APPLICANT CAN ONLY SHOW “PHYSICAL”
ACCESS - COUNTY TO REQUIRE DEED RECORDINGS ON PARCELS WITH NO “LEGAL”
ACCESS. (CONSISTENT
WITH OUR REQUEST AND ONLY REASONABLE ALTERNATIVE TO REQUIRING “LEGAL” ACCESS).
(CB)
·
Possible
fee reduction for tax producing projects like some commercial and industrial
uses.
NOT
DISCUSSED. (RS)
·
Off-site
sign regulations; too many local signs being posted off-site for various
reasons. Is this a code enforcement issue?
REQUIRES COMPLAINT FOR EACH SIGN. NO MORE COMMUNITY “SWEEPS” FOR
CODE VIOLATIONS. (CB)
·
Question
about the requirement of Temporary Special Event permits in county parks.
PERMITS
REQUIRED WHEN NOT IN REGIONAL PARKS AND MAYBE WHEN IN REGIONAL PARKS DEPENDING
ON TYPE OF EVENT. COUNTY LIKES COMMUNITY EVENTS AND WILL ALLOW EASIER PERMIT
PROCESS FOR THESE TYPES OF ACTIVITIES. (RS)
·
Percolation
tests being required for properties with adjacent or near studies having
already been done. Is this really needed?
EHS ADAMANT ABOUT REQUIRING PERC. TESTS AT SUBDIVISION STAGE TO ASSURE A SEPTIC SYSTEM WILL FUNCTION –
EVEN IN SOIL TYPES AND LOCATIONS WHERE SYSTEMS HAVE HISTORICALLY WORKED. (WOULD USE OF SOIL MAPS SUFFICE FOR MOST
AREAS IN DESERT?). EHS DOES NOT REQUIRE
PERC. TESTS FOR PARCELS 10 ACRES OR LARGER. PARTICULAR EMPHASIS IN
MOUNTAIN COMMUNITIES WHERE SOILS MAY NOT ALLOW SUFFICIENT LEACHING. (CB)
TOPICS DISCUSSED AT THE MEETING THAT WERE NOT IN THE
DISCUSSION LIST:
·
A
Minor Subdivision costs almost as much as most rural land is worth.
Subdivision FEES NOT LIKELY TO BE REDUCED. NOT
RESOLVED IS THE REQUIREMENT FOR LAND-DISTURBING INFRASTRUCTURE AND ROADS, ETC.
LONG BEFORE DEVELOPMENT OCCURS.(CB)
·
Commercial vs. residential requirements.
SPRINKLERS REQUIRED FOR ALL NEW COMMERCIAL AND RES. DEV. PER FIRE CODE –
EVEN IN AREAS WITH WATER PURVEYORS. (NOT ALWAYS REASONABLE FOR RURAL AREAS –
BUT DO WE PURSUE ALTERNATIVES?). NEED “COMPLETE” APPLICATIONS FOR FIRE TO KNOW
WHAT APPLIES. (CB)
·
EHS still requiring “Temp.
Special Event” permits for public gatherings in established County parks?
Special Event Permit - REQUIRED IF EVENT EXCEEDS RESTROOM/PARKING/ETC.
CAPACITIES – EVEN FOR REGIONAL PARKS. (CB)
Comment was made that only
regional parks with appropriate facilities for such function will be allowed to
hold events without temporary use permit applications. (RS)
By: Chuck bell for LVEDA
and Richard Selby for LUAC to the LVMAC
Revised
Revised
Revised
Revised